Same activity, same control
If a human in that seat needed dual control, the agent does too. If a model needed a SR 11-7 / SS 1/23-style review, an agent that wraps the model does too. Wrapping a foundation model in a planner does not wash the model risk off.
JPMorgan’s published split — sponsor review for low-risk uses, a separate risk committee and full model review for higher-risk ones — is the grown-up version of “we let staff use ChatGPT.” Register the models. Pin the prompts. Log the tools.
Regimes that already apply
EU AI Act and DORA push traceability and operational resilience for European entities and anyone selling into them. Payments agents pick up scheme rules, PSD-style strong customer authentication, and (for crypto) travel-rule obligations. Credit agents pick up fair-lending and adverse-action. There is no “AI exemption.”
What “verified production” means here
A named firm, a named workflow, a public primary source, and a sentence on what is still unknown. Survey percentages and vendor “can” language do not clear that bar. This observatory will append a case when those four exist. It will not overwrite an old case to make the story tidier.